1. OUR PRIVACY COMMITMENT
Smart Steps LLC (the “Company”, “we,” or “our”) is strongly dedicated to protecting the privacy of our customers’ personal information, which includes your personally-identifiable information (“PII”) and your Protected Health Information (“PHI”).
2. INFORMATION WE COLLECT
When you use the Services, we may collect PII, and sometimes PHI, from you. When you use the Website or the MobileApp, we may also automatically collect non-personally identifiable information from you.
PII that could be collected includes your full name, your address, your ZIP code, your photograph, your e-mail address, your telephone number, your credit card information, and other specific information that you volunteered to us.
PHI information that could be collected includes specific information that identifies you, plus information about your physical or mental health or the medical care that you have or may receive. We would only collect this information if you voluntarily posted or disclosed it on the Website or the MobileApp or if you voluntarily disclosed it to us in conversation with one of our call center vendor(s).
Non-personally identifiable information that could be automatically collected includes the IP address of your computer or mobile device, the make and model of your computer or mobile device, the type of web browser you are using, historical search data, information about your location (such as location information from your smart phone), and other electronic information. Such data is collected using cookies, web beacons, and other technologies.
3. HOW WE USE YOUR NON-MEDICAL INFORMATION
In general, we collect non-medical information from you so that we can more effectively serve you. Specifically, we may use the information in order to, among other things:
We will not rent or sell your information to third parties for marketing purposes. However, we may disclose:
4. HOW WE USE YOUR MEDICAL INFORMATION
When completing the User Profile, you may choose to enter Personal Health Information or you may share Personal Health Information when communicating with Smart Steps or a call center vendor by email or phone. Certain PHI about you is protected under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and applicable state law. We are required by law to maintain the privacy and confidentiality of PHI we collect, if any, and we operate the Company in accordance with state and federal laws governing the privacy and security of PHI.
SMART STEPS IS NOT A HEALTH CARE PROVIDER. If you receive medical or health care advice from a Health Care Provider, you should refer to your Health Care Provider’s Privacy Practices to obtain additional information about how your PHI may be accessed, used, and disclosed under HIPPA.
We may disclose PHI to courts or law enforcement agencies as required by law or legal process, and we may disclose PHI in life threatening situations or to protect the safety of any person.
We use “cookies” to collect information. Cookies are data files that are stored on your hard drive and that are used, generally, to improve your online experience. For example, cookies can be used save your user credentials for future logins, to enable certain features of the Website and the MobileApp, and to track your usage of the Website and the MobileApp. We also may work with third party contractors and vendors who will place or read cookies on your hard drive. You can set your web browser to stop accepting cookies or to warn you before it accepts cookies. However, if you do not accept cookies certain functionality of the Website and the MobileApp will not work.
We also may use web beacons to collect information. Web beacons are transparent graphic images placed on the Website or the MobileApp or in an email that tell us about your interactions with us. For example, a web beacon may tell us if you have opened an e-mail from us.
6. SECURITY MATTERS
We have put in place industry-standard technology and administrative processes and privacy and security measures designed to safeguard and protect information under our control, including any PII or PHI, from unauthorized access, disclosure, or use. However, we cannot guarantee or warrant that such unauthorized access, disclosure, or use will never occur. You acknowledge and agree, therefore, that any information or communication that you send or transmit to us, or that is stored by us, is communicated, transmitted, and/or stored at your own risk.
We will make all legally required disclosures regarding any breach of security or confidentiality with regard to your PII. Any such required disclosures will be made by e-mail or by posting to the Website or the MobileApp, without unreasonable delay.
7. LINKS TO THIRD PARTY WEBSITES
8. CHANGING YOUR PERSONAL INFORMATION
You may update, change, or delete some of the information you have previously provided to us. You may update your information through the Website.
The Website and the MobileApp may make available functionality that allows you to communicate online and to post or upload personal information, including PII and PHI. THE COMPANY IS NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL INFORMATION, INCLUDING PII AND PHI, THAT YOU VOLUNTARILY SUBMIT THROUGH THE WEBSITE, THE MOBILEAPP, OR BY ANY OTHER USE OF THE SERVICES.
You understand and agree that all of the personal content, communications, and disclosures that you post or upload to the Website or the MobileApp, and that are visible to other users of the Website or the MobileApp becomes public information. In addition, you agree that by making such personal content, communications, and disclosures you grant to the Company a perpetual, irrevocable, worldwide, license to publish, display, copy, transmit, distribute, and otherwise use such personal content, communications, and disclosures in any media or medium and in any format now known or hereafter developed.
You agree that you will not use the Website or the MobileApp to post or upload any personal content, communications, or disclosures that violate or infringe upon any rights of any party, including, but not limited to, any person’s copyright, trademark, or other intellectual property rights. In addition, you agree that you will not use the Website or the MobileApp to post or upload any personal content, communications, or disclosures that are abusive, offensive, hateful, obscene, pornographic, or sexually explicit.
10. HOW TO OPT OUT OF COMMUNICATIONS FROM US
You may opt-out of receiving most communications from us by sending an e-mail to email@example.com with the word UNSUBSCRIBE in the header or text. However, as long as your account is open you will be unable to opt-out of certain minimal communications from us, including policy updates and certain account and billing matters.
12. HOW TO CONTACT US